Meeting
with
Washington
State
Department
of
Ecology
Date:
June
17,
2003
Attending:
from
Washington
State
Department
of
Ecology
(
WDOE):
Bob
Burmark,
Matt
Kadlec,
Rob
Rieck,
Craig
R.
McCormack,
Chris
Peredney,
Randall
Marshall
from
US
EPA:
Margaret
Sheppard
from
Garrett
Services,
Inc.:
Andy
Garrett
from
Albemarle
Corporation:
Joe
Miller,
Mick
Kassem
Randall
Marshall
opened
the
meeting
with
introductions.
Margaret
Sheppard
from
EPA
provided
information
on
the
environmental
and
health
effects
of
n­
propyl
bromide
(
nPB)
(
see
attachment/
Docket
A­
2001­
07,
item
IV­
B­
3)
and
EPA's
proposed
rule.
She
summarized
EPA's
proposed
acceptability
decision
for
nPB,
including
the
use
condition
that
nPB
formulations
used
in
SNAP
end
uses
must
contain
no
more
than
0.05%
isopropyl
bromide
(
iPB)
before
adding
other
chemicals.

Representatives
of
the
WDOE
if
the
iPB
came
from
original
manufacture
or
if
it
was
created
in
the
process
of
use.
Ms.
Sheppard
stated
that
it
is
her
understanding
that
it
comes
from
the
original
manufacture.
Representatives
from
Albemarle
said
that
their
internal
guideline
for
iPB
contamination
is
300
ppm,
or
0.03%.

WDOE
staff
asked
about
some
issues
related
to
ecological
impacts.
They
asked
if
EPA
had
derived
a
reference
dose
(
RfD)
or
a
slope
factor.
Ms.
Sheppard
replied
that
EPA
had
estimated
a
reference
concentration
for
inhalation,
since
this
was
the
most
probable
route
of
exposure.
She
also
mentioned
that
there
was
insufficient
information
that
nPB
is
carcinogenic
to
develop
a
slope
factor.
Chris
Peredney
asked
if
EPA
had
studied
immunotoxicity
of
nPB,
and
Ms.
Sheppard
replied
that
the
SNAP
program
had
not.
Mr.
Marshall
asked
about
testing
for
aquatic
toxicity,
particularly
the
echinoderm
fertilization
test.
Ms.
Sheppard
replied
that
the
only
aquatic
toxicity
testing
that
she
knew
of
for
nPB
was
testing
on
fathead
minnows.
Mr.
Kassem
indicated
that
he
believed
Albemarle
has
a
copy
of
these
data,
if
the
WDOE
is
interested
in
it.

WDOE
staff
requested
an
overview
of
the
types
of
applications
where
nPB
is
used,
and
how
much
people
might
be
exposed
to.
Ms.
Sheppard
described
the
major
applications,
including
vapor
degreasing,
aerosol
solvents
(
especially
for
electronics
and
electrical
equipment),
and
as
a
carrier
solvent
in
spray
adhesives
for
use
in
foam
fabrication.
Ms.
Sheppard
mentioned
that
she
has
heard
rumors
of
use
of
nPB
in
dry
cleaning,
but
this
is
not
an
application
covered
by
the
SNAP
program.
Mr.
Miller
and
Mr.
Kassem
mentioned
that
Albemarle
had
considered
dry
cleaning
at
one
time,
but
only
when
used
in
air­
tight
machines.
Ms.
Sheppard
also
described
the
worldwide
market
for
nPB
in
the
three
major
industrial
sectors
and
typical
workplace
exposure
levels
for
different
applications.

WDOE
staff
asked
about
the
possibility
of
recycling
spent
solvent.
Albemarle
representatives
said
that
there
is
not
yet
recycling
in
the
U.
S.
because
there
is
not
quite
enough
2
volume
of
nPB
to
make
recycling
viable.
However,
it
is
possible
that
this
could
happen
in
the
future
if
the
volume
of
nPB
use
increases
slightly.
There
would
be
issues
of
contamination
with
spent
solvent,
and
a
need
to
reduce
residual
moisture.

The
toxics
cleanup
staff
asked
about
community
exposure.
Ms.
Sheppard
said
that
EPA
modeled
community
exposure
using
EPA's
SCREEN
3
model,
with
two
scenarios
of
exposure
to
people
living
next
door
to
facilities
using
spray
adhesives
containing
nPB.
Craig
McCormack
asked
if
EPA
had
developed
an
RfC.
Ms.
Sheppard
said
that
the
SNAP
program
had
developed
a
community
exposure
guideline
using
EPA's
RfC
guidelines,
and
that
it
was
basically
an
estimated
RfC.
However,
the
community
exposure
guideline
is
not
in
the
Integrated
Risk
Information
System
(
IRIS).
Mr.
McCormack
suggested
that
it
would
be
useful
for
EPA
to
go
through
a
formal
process
of
developing
an
RfC
through
the
National
Center
for
Environmental
Assessment
(
NCEA)
and
putting
it
in
IRIS.
He
also
asked
about
particular
individuals
he
knows,
and
who
has
reviewed
the
toxicological
data.

Robert
Rieck
said
that
he
thought
it
was
appropriate
to
keep
nPB
out
of
wastewater.
Ms.
Sheppard
agreed
that
this
sounded
appropriate.
Joe
Miller
said
that
nPB
hydrolyzes
more
quickly
that
the
chlorinated
solvents,
and
so
would
have
less
impact.
Currently,
Albemarle
recommends
to
its
customers
that
the
spent
solvent
is
incinerated.
Albemarle
offers
free
pickup
and
disposal
of
spent
solvent
for
its
customers.
Mick
Kassem
offered
to
send
a
copy
of
the
letter
Albemarle
sends
to
its
customers,
requesting
that
they
ensure
the
spent
solvent
is
incinerated.
